Ad primum secundum et tertium arlos dicta allegacons deponit
et dicit that hee this deponent being a Waterman by
profession and liveing in Lymehouse neare unto Dickshore
arlate, was with his wherrey upon the River of Thames
att sch time as the ship the Saint Jacob arlate
came a shore at Dickshore aforesaid which was upon or about
the time arlate And saith that in case anie damage
did happen unto the said ship the Saint Jacob by such her
comeing a shoare there the same happened and soe fell
out by the unskillfullnes or negligence of the Master and
Company of the said shipp only, and not by any default
of the arlate Mr Hussey or his ship the Phillip arlate
or by any Anchor belonging to her And he further saith
that by the Custome of the River of Thames
and by an Order of the Trinitye
house arlate Noe Master of a ship or Marriner of what
place soever may or ought to bring up theire ships (laden)
into the said River of Thames without a sufficient and able
Pilott abord her and such a one as is approved on by the
said house, which said Custome and order this deponent
saith hee hath knowne to bee observed by the space of
theise 20 yeares and upwards dureing which tyme
hee hath lived at Lymehouse aforesaid and frequented
the said River. and hath bin credibly informed and
beleeveth the same hath bin observed for tyme out
of mind and beyond the memory of man before that Ulterius
deponit that the said ship the Saint Jacob at the tyme of
her said comeing ashore at Dickshoare as aforesaid
had neither a Pilot nor Master abord her which hee knoweth
because hee this deponent and his contest James Symmo[?XX]
did